Over at Concurring Opinions Dave Hoffman reacts to manuscript submission "requirements" at the California Law Review. As Dave notes, requirements 4 and 5 could easily pose something of a problem for empirical pieces. To be fair to the California Law Review, it is possible that these requirements are routinely waived or, simply, ignored. Then again, maybe not. Regardless, such rules certainly convey a tone that will deflect some empirical manuscripts elsewhere. Even for folks still inclined to publish in student-edited journals (rather than the growing number of faculty-edited, peer-reviewed journals), why bother with one that appears indifferent to empirical work? And, alas, maybe that is simply the outcome the editors' desire. Given the palpable trend in legal scholarship today toward empirical scholarship, however, CLR's submission requirements invite some level of risk to that Review.